Case Summary of Lochner v. New York ( 198 U.S. 45)

Case Summary of Lochner v. New York (198 U.S. 45)

A law was passed in the State of New York called the Bakeshop Act of 1895 which is under Section 110 of the labor law of the State of New York seeking to limit the working hours of bakers to ten a day and 60 a week.  Joseph Lochner who owned a small bakery in Utica was fined $50 for permitting an employee to work more than 60 hours in a week.  Lochner was convicted in the trial court. On appeal, he challenged the constitutionality of the Bakeshop Act arguing that the law caused interference in his right to pursue a lawful trade.  On the other hand, the state argued that the law was a valid exercise of police power as it sought to protect the health and safety of employees working in bakeries.

The issue in this case is whether the Supreme Court can invalidate a state law restricting the hours employees could work in the baking industry as a violation of the freedom of contract guaranteed by the Due Process Clause of the Fourth Amendment. Another issue is whether the law is a valid exercise of the police power of the state.

The Supreme Court ruled that Section 110 of the labor law of the State of New York which provides that no employees shall be required or permitted to work in bakeries for more than sixty hours in a week or ten hours a day is not a legitimate exercise of the police power of the state but an unreasonable, unnecessary and arbitrary interference with the right and liberty of the individual to contract in relation to labor. The court said that “There is no reasonable ground for interfering with the liberty of person or the right of free contract by determining the hours of labor in the occupation of a baker.”

Individuals have a right to enter into contracts in relation to their business.  This is a right protected under the Fourteenth Amendment of the Federal Constitution.  The said provision provides that no state can deprive a person of life, liberty and property without due process of law. The right to purchase or sell labor is a liberty protected under the Fourth Amendment. 

In previous cases, the court has validly restricted or limited life, liberty and property under the exercise of police powers.  For instance, the courts have ruled that limiting the number of working hours in mines have been ruled to be a valid exercise of police power. 

However, the law which is the subject of controversy should have a direct connection to a danger that would compromise the public health or the health of employees before it may restrict the hours of labor in any trade or profession.  In the case of workers in mines restricting the hours worked has a direct relation to public health. However, for the bakers working in bakeries, the connection to the public health or welfare was considered to be too remote.

The impact of this decision is that it virtually declared that in a capitalistic economy minimum government interference in businesses should be the policy and that business should be allowed to enter into various contracts. 

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